Curtis B. Keene - Page 17




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          Commissioner, supra at 165; Goza v. Commissioner, supra.                    
          Further, as the Court of Appeals for the Fifth Circuit has                  
          remarked: "We perceive no need to refute these arguments with               
          somber reasoning and copious citation of precedent; to do so                
          might suggest that these arguments have some colorable merit."              
          Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).                 
          Suffice it to say that petitioner is a taxpayer subject to the              
          Federal income tax, see secs. 1(a)(1), 7701(a)(1), (14), and that           
          compensation for labor or services rendered constitutes income              
          subject to the Federal income tax, sec. 61(a)(1); United States             
          v. Romero, 640 F.2d 1014, 1016 (9th Cir. 1981); see also sec. 86            
          regarding the taxability of unemployment compensation.                      
               We likewise reject petitioner’s argument that the Appeals              
          officer failed to obtain verification from the Secretary that the           
          requirements of all applicable laws and administrative procedures           
          were met as required by section 6330(c)(1).  The record shows               
          that the Appeals officer obtained and reviewed transcripts of               
          petitioner’s accounts for 1997 and 1998.                                    
               Federal tax assessments are formally recorded on a record of           
          assessment.  Sec. 6203.  “The summary record, through supporting            
          records, shall provide identification of the taxpayer, the                  
          character of the liability assessed, the taxable period, if                 
          applicable, and the amount of the assessment.”  Sec. 301.6203-1,            
          Proced. & Admin. Regs.                                                      






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